Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC dismissed the appeal, holding that Section 3C's non-obstante clause does not curtail additional duty levied under Section 3B; rather Section 3C limits duties imposed by any other law to the maximum chargeable under the Stamp Act, which includes both primary duty under Section 3 and additional duty under Section 3B. The Single Judge correctly rejected the appellant's contention that Section 3C operates to cap or negate Section 3B liabilities. The appeal lacks merits and is dismissed with costs of Rs.25,000 payable by the appellant to the respondent.
The HC dismissed the appeal, holding that Section 3C's non-obstante clause does not curtail additional duty levied under Section 3B; rather Section 3C limits duties imposed by any other law to the maximum chargeable under the Stamp Act, which includes both primary duty under Section 3 and additional duty under Section 3B. The Single Judge correctly rejected the appellant's contention that Section 3C operates to cap or negate Section 3B liabilities. The appeal lacks merits and is dismissed with costs of Rs.25,000 payable by the appellant to the respondent.
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